CMS, ONC kick off EHR incentives training program
The session was the first in series hosted by the Centers for Medicare & Medicaid Services (CMS) and ONC, and featured an overview of the new programs by leadership and policy experts from both agencies.
The final rules establish definitions for Stage 1 meaningful use for 2011-12, said Elizabeth Holland, of CMS’ Office of E-Health Standards and Services.
The meaningful use objectives and clinical quality measures have changed significantly from the initial proposal, Holland said, and many changes were based on public comments. For example, concerns about attestation and collecting and recording information led to a simplified process, and Stage 1 clinical quality measures are limited to those that have electronic specifications.
Eligibility requirements differ for the Medicare fee-for-service program, Medicare Advantage and Medicaid, and each has a component for eligible professionals and one for eligible hospitals.
Under Medicaid, the definition of eligible professional is more inclusive than the Medicare definition, including nurse practitioners, certified nurse midwives, dentists and physician assistants working in Federally Qualified Health Centers (FQHC) or Rural Health Clinics (RHC) led by a physician assistant. Eligible facilities include acute-care hospitals, which now include critical-access hospitals—a major change from the initial rule—as well as children’s hospitals, said Holland.
Stage 1 incentives encompass 25 objectives for eligible professionals and 24 for eligible hospitals. Every objective is coupled with a measure that provides a mechanism for eligible professionals or eligible hospitals to demonstrate meaningful use to CMS for Medicare incentives or to states’ Medicaid program, said Travis Broome, health insurance specialist at CMS.
Objectives are divided into a core required set and a menu set, in which five can be deferred. Eligible professionals must report on 20 of 25 objectives; eligible hospitals will need to report on 19 of 24 to be considered meaningful users, he said.
The core set of objectives includes statutory requirements that were in the HITECH Act, “as well as others that we considered foundational [without which] other objectives of meaningful use would not be possible,” said Broome.
Stage 1 menu set objectives will likely become core objectives for Stage 2, said Broome.
Eligible professionals can receive either a Medicare or a Medicaid incentive payment in a given year, but some Subsection D hospitals and acute care hospitals under Medicaid can receive both, according to Jessica Kahn, technical director for health IT at CMS.
If such a facility demonstrates meaningful use to CMS for Medicare for EHR incentive payment, “it would be deemed a meaningful user for Medicaid so it doesn’t need to duplicate reporting in two different locations.” CMS would inform the state that the hospital has met meaningful use requirements and that hospital would be considered a meaningful user for Medicaid as well, she said.
For 2011, eligible professionals, hospitals, and critical access hospitals seeking to demonstrate meaningful use must submit aggregate numerator, denominator and exclusion data to CMS or to states by attestation, Kahn said. From 2012 on, information must be submitted to states or CMS electronically.
Medicare meaningful use program participants will be able to register via an online national level repository, according to Michelle Mills, policy analyst at CMS. Medicaid does not have an online posting requirement for providers who receive incentives under this program—states will administer and oversee the Medicaid process and determine Medicaid eligibility, she said.
A credible certification program has been created to assure all stakeholders that EHR technology will include capabilities needed for providers to achieve meaningful use, said Carol A. Bean, PhD, ONC’s division director for certification and testing.
ONC is now accepting applications for Authorized Testing and Certification Bodies (ATCB) that will test and certify home-grown and commercial EHR products and systems. The office expects to have ATCBs authorized within the next two months, and products will begin to be certified under the temporary program in the late summer to early fall, said Bean, adding that testing and certification will be done by the same ATCB in the temporary certification program, but these functions will be separated in the permanent program.
Both programs, according to Bean, will include a “public service feature,” the Certified Health IT Products List, which will aggregate all information about certified products into one website, including vendor information, version numbers and the specific criteria to which products or modules have been certified. It will allow anyone to query the system to determine whether the package or modules they have will meet criteria for meaningful use.
A short question-and-answer session followed the presentations, and a sample of those are:
Q: Do providers need to practice in FQHCs or RHCs to participate in the Medicaid incentive program? What about community clinic providers that are not part of FQHCs?
A: In the Medicaid program only, providers can participate by meeting patient volume thresholds—for most practitioners, that will be 30 percent Medicaid patients—or by participating in FQHCs or RHCs … If 30 percent of your patient volume comprises Medicaid patients, then you’re eligible, no matter what setting you’re in.
Q: The core quality measures seem very primary-care focused. What does that mean for community clinics that perhaps focus on specialized care, such as OB or family planning?
A: Some of the core measures are very primary-care-focused, but in the additional measure set are measures that correspond to your practice. In some circumstances, you have the option of having a null denominator, and it doesn’t exclude you from being a meaningful user.
Q: Under final rules for certification and meaningful use, do stand-alone laboratory information systems require EHR certification, in order for client eligible professionals and hospitals to qualify for incentive payments under HITECH?
A: No. To qualify, they have to demonstrate meaningful use of EHR technology. This program does not extend to labs, nor to laboratory information systems.